BILL ANALYSIS                                                                                                                                                                                                    Ó







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        |Hearing Date:June 27, 2011         |Bill No:AB                         |
        |                                   |417                                |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                          Senator Curren D. Price, Jr., Chair
                                           

                       Bill No:        AB 417Author:B. Berryhill
                        As Amended:June 20, 2011 Fiscal:    No

        
        SUBJECT:  Structural pest control.
        
        SUMMARY:  Prohibits a city, county, or city and county from 
        prohibiting a licensee of the Structural Pest Control Board from 
        engaging in the particular business, occupation, or profession for 
        which he or she is licensed under the Structural Pest Control law.

        Existing law:
        
        1) Prohibits a city or county from prohibiting a person or group of 
           persons, authorized by one of the agencies in the Department of 
           Consumer Affairs (DCA) by a license, certificate, or other such 
           means to engage in a particular business, from engaging in that 
           business, occupation, or profession or any portion thereof.  
           (Business and Professions Code (BPC) § 460 (a))

        2) Provides for the licensing and regulation of more than 24,000 
           structural pest control operators, field representatives, 
           applicators and registered structural pest control companies by the 
           Structural Pest Control Board (SPCB or Board) within the Department 
           of Pesticide Regulation (DPR).

        3) Provides that the practice of structural pest control includes 
           engaging in, offering, advertising, soliciting, or the performance 
           of:  identification of infestations or infections; making an 
           inspection to identify infestations or infections of structures by 
           pests or organisms; making inspection reports, recommendations, 
           estimates, and bids; making contracts, or bidding for,  or the 
           performance of any work including, making structural repairs or 
           replacements  , or the use of pesticides, insecticides, rodenticides, 





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           fumigants, or allied chemicals or substances, or mechanical devices 
           for the purpose of eliminating, exterminating, controlling or 
           preventing infestations or infections of pests, or organisms.  (BPC 
           § 8505)

        4) Provides for structural pest control operators, field 
           representatives, and applicators to be licensed in as many as three 
           specified areas of pest control:  Branch 1 - Fumigation, Branch 2 - 
           General pest, and Branch 3 - Termite.  (BPC § 8560)

        5) Specifically provides that the practice of the Branch 3 - Termite 
           license relates to the control of wood-destroying pests or 
           organisms by the use of insecticides, or structural repairs and 
           corrections, excluding fumigation with poisonous or lethal gases.  
           (BPC § 8560)

        6) Licenses and regulates contractors by the Contractors State License 
           Board within the Department of Consumer Affairs (DCA) and exempts 
           from the licensing requirement, a licensed structural pest control 
           operator acting within the scope of his or her license.  (BPC § 
           7051)

        This bill:

        1) Prohibits a city, county, or city and county from prohibiting a 
           licensee of the SPCB from engaging in the particular business, 
           occupation, or profession for which he or she is licensed under the 
           Structural Pest Control law.

        FISCAL EFFECT:  None.  This bill has not been keyed "fiscal" by 
        Legislative Counsel.

        COMMENTS:
        
        1. Purpose.  This bill is sponsored by the  Pest Control Operators of 
           California  (Sponsor).  According to the Author, "AB 417 simply 
           clarifies to local building inspectors in statute the ability to 
           make repairs which were lost when the Structural Pest Control Board 
           was removed from the jurisdiction of the Department of Consumer 
           Affairs and placed under the authority of the Department of 
           Pesticide Regulation."

        The Author notes that when the SPCB was moved from under DCA, the 
           ability for a licensed pest control operator to secure a building 
           permit was impacted.  SPCB licensees need these permits to make 
           repairs caused by pest damage.





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        2. Background.  General provisions of the Business and Professions 
           Code prohibits a city or county from prohibiting a person licensed 
           by a board or bureau under DCA to engage in that licensed business, 
           occupation, or profession or any portion thereof (BPC § 460 (a)).  

        In 2009,  ABX4 20  (Strickland, Chapter 18, Statutes of 2009) made a 
           number of changes to several regulatory agencies, including, moving 
           the SPCB from the DCA into the DPR.  In transferring the Board 
           outside of DCA it has been argued that the licensed pest control 
           operators no longer meet the criteria of Section 460 (a), since the 
           SPCB is no longer under DCA.  This has direct impact on the ability 
           of pest control operators, operating under their licenses, to 
           obtain building permits and have their modifications and repairs 
           signed off on by local building inspectors.  

        This bill would address this issue by mirroring the provisions of BPC 
           § 460 (a) in the Structural Pest Control Act.

        3. Repairs by Pest Control Licensees.  The Structural Pest Control Act 
           provides for the licensing and regulation of structural pest 
           control operators, field representatives, and applicators and the 
           registration of structural pest control companies by the SPCB.  The 
           SPCB was created by the California Legislature in 1935.  Prior to 
           that time structural pest control was regulated by the Contractors 
           State License Board.  By application and examination, the SPCB 
           issues licenses in three specified areas of pest control.  All 
           companies and their branch offices must be registered by the SPCB.

             Branch 1 - Fumigation.  The control of household and wood 
             destroying pests or organisms by fumigation with poisonous or 
             lethal gases.

             Branch 2 - General pest.  The control of household pests, but 
             excludes fumigation.

             Branch 3 - Termite.  The control of wood destroying pests or 
             organisms by use of insecticides, or structural repairs and 
             corrections, excluding fumigation.

           When an inspection finds wood destroying pests in a structure, the 
           report must include recommendations for corrective measures.  
           Corrective measures may include the repair or replacement of 
           structural elements which have been damaged by pests or organisims. 
            At the consumers choice, the consumer may make the necessary 
           corrective repairs in any of several ways, including:  using the 





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           services of a licensed contractor, or contracting with a Branch 3 
           licensee for those repairs and corrections.

           The Contractors State License law exempts pest control operators 
           acting with the scope of their license from the contractor 
           licensing requirement (BPC § 7051).  The CSLB's Building Official 
           Information Guide states, "Structural Pest Control Operators are 
           not required to hold a contractor's license when operating within 
           the scope of their license.  Only a Branch 3 Licensed Structural 
           Pest Control Operator may contract and pull permits for the repair 
           or replacement of wood damaged by wood-destroying pests or 
           organisms."

        4. Hearing on Governor's Elimination, Consolidation and Reorganization 
           Proposals and Consolidation of the Structural Pest Control Board 
           under the Department of Pesticide Regulation.  In the May Revision 
           of the 2009-2010 State Budget (May Revise), the Administration made 
           a number of recommendations to eliminate and consolidate a number 
           of boards and regulatory programs.  In the summer of 2009, the 
           Business, Professions and Economic Development Committee (BP&ED 
           Committee) convened a hearing on the Governor's Elimination, 
           Consolidation and Reorganization Proposals made in the May Revise.  
           The Budget Conference Committee had requested that the Committee 
           consider a number of the specific elimination, consolidation and 
           reorganization proposals made by the Governor, as well as other 
           consolidation proposals identified by the BP&ED Committee.  In the 
           hearing, the BP&ED Committee received testimony from the 
           Administration, DCA, boards and bureaus that would be affected by 
           the proposed changes, and also from the Legislative Analyst's 
           Office (LAO), the Center for Public Interest Law, professional 
           associations, members of the regulated professions, and members of 
           the public.  The BP&ED Committee made its recommendations in a 
           Report to the Conference Committee.  Those recommendations and the 
           legislative changes necessary to implement the recommendations were 
           the bases for ABX4 20.

        At that hearing, the BP&ED Committee considered 13 separate 
           consolidation or elimination proposals, including whether the SPCB 
           should be consolidated under the DPR.  Ultimately the Committee, 
           approved on an 8-0 vote, a motion to consolidate the Structural 
           Pest Control Board within the Department of Pesticide Regulation, 
           keeping the board and its licensing and regulatory functions intact 
           and maintaining the transparency and public input of the board's 
           regulatory operations.  Those changes were included in ABX4 20.

        In placing the SPCB under the oversight of DPR , the BP&ED Committee 





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           noted that the eradication of pests and application of dangerous 
           chemicals and pesticides by pest control operators and pest control 
           companies presents significant environmental and health and safety 
           issues.  Although the regulation of business that inspects 
           structures for pests and infestations is a significant portion of 
           the activities of the SPCB, the application of pesticides to 
           eradicate pests is an underlying risk to consumers and the public.  
           It is appropriate that efficiencies and the safety of the public 
           might be better protected by consolidating the functions of the 
           SPCB within the DPR.

        5. Arguments in Support.  In sponsoring the bill, the  Pest Control 
           Operators of California  state that the bill would simply allow 
           licensed pest control operators to have the same right to make 
           structural repairs under the Department of Pesticide Regulation, as 
           they previously had under the Department of Consumer Affairs."


        SUPPORT AND OPPOSITION:
        
         Support:   Pest Control Operators of California (Sponsor)

         Opposition:   None on file as of June 21, 2011



        Consultant:G. V. Ayers